Officer-as-a-Service: Organise ordering duties as a managed service

With every new law, the list of functions that require ordering grows. The GDPR requires a data protection officer, the LkSG requires a human rights officer, the NIS 2 directive requires an information security officer, and the AMLA calls for a money laundering officer. On average, medium-sized companies today have to fill between six and twelve roles, document them and keep them auditable. Classic models link an individual contract, a service provider and an Excel file per role.

Officer-as-a-Service reverses this logic. Instead of multiple service providers with different contracts, tools and reporting formats, the model bundles the appointed people, the platform and the audit templates under one contract. This article describes how the model works legally, operationally and cost-wise, which roles can be sensibly outsourced, where the limits lie and how the transition from today's patchwork to a uniform compliance organisation is achieved.

Officer-as-a-Service combines three building blocks. Firstly: properly appointed natural persons with the required qualifications and appointment documents in accordance with Art. 37 GDPR, Section 9b GwG, Section 5a IT-SiG or comparable standards. Second: a central compliance platform in which risks, measures, audits, incidents and evidence are mapped across roles. Third: an SLA with response and processing times that defines in advance who does what and when. Responsibility towards supervisory authorities remains with the company; the representative works according to instructions within the framework of his legal independence.

The difference to classic consulting services is substantial. Consultants recommend that Officer-as-a-Service takes on operational responsibility. An appointed person in accordance with Art. 37 GDPR cannot withdraw by sending a memo, but is the contact person for the supervisory authority and those affected. CIVAC delivers the model as a compliance platform and officer-as-a-service over 25 officer roles, with a workspace in which appointment certificates, audit templates and evidence are stored centrally. The appointment certificate, signed, filed, verifiable.

Officer-as-a-Service works where the law expressly allows the appointment of external persons. This is the case for most roles: Art. 37 Para. 6 GDPR allows the external DPO, Section 7 Para. 3 GwG the external money laundering officer, Section 6 ASiG the external occupational safety specialist, Section 12 ArbSchG the external company doctor, the regulations on fire protection, dangerous goods and radiation protection allow external representatives with the appropriate qualifications.

There are limits for a few roles with mandatory internal ones anchoring. By law, the compliance officer does not necessarily have to be appointed externally; In regulated industries such as banks or insurance companies, Section 25h KWG actually prescribes internal compliance officers. The inclusion officer according to Section 181 SGB IX must also be an employee. In these cases, CIVAC works with the platform model: your internal staff uses the workspace, the audit templates and the reporting line without the order itself being placed externally. Others run compliance like a filing cabinet. We run it like software.

CIVAC fully maps 25 representative roles. In the area of ​​data protection and privacy: data protection officer. In the area of ​​governance and compliance: compliance officer, AGG complaints office, whistleblower protection reporting centre according to HinSchG. In the area of ​​IT security and NIS-2: Information security officer and ISO/IEC 27001 ISMS. In the area of ​​occupational safety and health: Occupational safety specialist, company doctor, fire protection officer, hygiene officer.

In the area of ​​environment and hazardous substances: hazardous materials officer, environmental officer, waste officer, water protection officer, pollution control officer, radiation protection officer. In the area of ​​logistics and safety: dangerous goods officer, incident officer, emergency officer. In the area of ​​money laundering and finance: money laundering officer. In the area of ​​supply chain and quality: LkSG representative, supplier auditor, quality management representative. In the area of ​​ESG: ESG and sustainability officer. In the construction sector: construction manager and SiGeKo. In the area of ​​social affairs: inclusion officer. Each role is documented with a legal basis, qualification requirements, typical hours and audit templates. The auditor calls, the evidence is ready.

CIVAC offers the model in two versions. Variant one is the platform licence: you keep all orders internally, your own representatives work in the workspace with audit templates, risk registers, reporting paths and reporting. Suitable for companies with an established internal compliance department that want to standardise methodology, tooling and audit capability without outsourcing orders.

Variant two is officer-as-a-service in the narrower sense: an external representative appointed in accordance with the relevant law takes on the role for individual or all 25 functions. The appointment certificate is signed, stored in the workspace and reported to the responsible supervisory authority, where necessary. Licence the workspace for your internal representatives or have our representatives order it. Both models live in the same platform with the same 490 audit templates, the same 93 controls for ISO/IEC 27001:2022 and the same EU data residency standard. The difference lies in the formal responsibility and the internal capacity requirements, not in the depth of the content.

Compliance incidents are based on deadlines, not availability. The 72-hour period according to Art. 33 GDPR begins with the acknowledgment. Deadline begins as soon as we become aware of it. According to Section 32 of the new BSIG, the NIS 2 early warning must be submitted to the BSI within 24 hours, and the follow-up report within 72 hours. Anyone who does not reach a representative within one working day will lose the deadline. This is exactly where the CIVAC SLA comes in: initial response within two working days, escalation path with defined substitution rules, documentation of every reaction in the workspace.

The reporting line according to Art. 38 Para. 3 GDPR or Section 7 Para. 5 GwG stipulates that the representative reports directly to the highest management level. In the classic model, the reporting line often ends in the managing director's inbox, without a structured format. CIVAC structures the reporting line with standardised quarterly reports, incident reports and an audit dashboard that shows the status of each role in an overview. This creates a reporting line that is audit-proof, documented and Section 38-proof.

In the classic model, each role is assigned individually, often to different providers. A medium-sized company with 250 employees that employs DSB, ISB, GwB, SiFa, company doctor, fire protection, hazardous substances and LkSG externally typically pays between 30,000 and 70,000 euros per year, spread over eight contracts, eight reporting formats and eight response times. In addition, there are the internal hours for coordination, control and audit preparation, often 200 to 400 hours per year.

In the Officer-as-a-Service bundle model, the price is between 24,000 and 60,000 euros per year, depending on the number of roles and industry, with a contract, an SLA and an audit dashboard. Experience has shown that internal control hours fall by 40 to 60 percent because the platform takes over the coordination. The economic leverage lies less in the pure licence price than in the coordination time saved and the drastically reduced response time from two to six weeks to two working days. In the event of an NIS 2 incident, this difference can determine the amount of a fine of up to 10 million euros or 2 percent of group sales.

Moving to Officer-as-a-Service typically takes 60 to 90 days. In the first two weeks, existing appointment certificates, contracts and risks are recorded and stored in the workspace. In weeks three to six, the new external people will be appointed, and at the same time, old contracts will be terminated or suspended. The data protection supervisory authority will be informed of the order in accordance with Article 37 (7) GDPR, and the AMLA supervisory authority will be informed of the order in accordance with Section 7 (4) GwG, if relevant.

From week seven, regular operations will begin with defined quarterly reports, audit templates and incident reporting paths. It is important that the old files are handed over cleanly so that historical evidence is not lost. CIVAC takes over the migration of the existing documents into the workspace schema and maps the reporting line to the respective board or managing director. The appointment certificate, signed, filed, verifiable. The advantage of a clearly timed transition: Audit capability is guaranteed throughout the change and not only after the migration has been completed.

Officer-as-a-Service is not a panacea. Three risks are underestimated in practice. First: dependency on the provider. If you combine all roles, you should contractually establish an exit plan with a data migration path and handover deadlines. Second: quality of the people appointed. A DPO without practice in your industry is riskier than an experienced in-house employee with GDPR training. Get proof of qualifications per role, not just a company flyer.

Third: data residency and sub-processors. Compliance data is particularly sensitive because it contains all of your company's violations and vulnerabilities. Request EU data residency, contractually secured sub-processors according to Art. 28 GDPR and ISO/IEC 27001:2022 certified hosting locations. CIVAC works exclusively with EU data residency, ISO 27001:2022 certified ISMS and 93 documented controls. Check these points before signing the contract; After the contract has been concluded, a correction is significantly more complex.

Officer-as-a-Service is not a label, but an operational contract with clear obligations, orders and response times. Anyone who controls 25 roles via Excel and individual consultants spends more time on coordination than on content. A bundled model creates a reporting line, an audit dashboard and a contact person without restricting the legal independence of the individual representatives.

CIVAC is a German compliance platform and officer-as-a-service with 25 live roles, 490 audit templates, 93 controls according to ISO/IEC 27001:2022 and EU data residency. Turn reading into an assignment. Write to info@civac.de or use the contact form on civac.de/faq. In the 30-minute initial consultation, we will clarify which roles you need to fill today, which ones are already covered internally and which mix of platform licence and appointed officer roles makes sense for your size, industry and risk situation.